Stroud District Green Party welcomes many aspects of the Draft Regional Spatial Strategy (RSS), and broadly supports the Strategic Sustainability Assessment (SSA). We enclose below key points and recommendations to the consultation on the Draft RSS.

 
Many of the points we raise are supported by the SSA, but have so far not been included in the RSS. We consider it is vital for Stroud District and the region that the final RSS addresses and resolves the issues identified in the SSA, which will produce a very different and much improved RSS. We consider the Draft RSS in its present form to have a number of key fundamental flaws. Our submission considers these in more detail, giving background reasons and supporting evidence.

Cllr. Philip Booth
Ms Rosie Reed
Cllr. John Marjoram
Cllr. Martin Whiteside

With special thanks to Dr Carol Kambites and other Stroud District Green party members who helped with this submission.

28th August 2006.

Sections in this report:

1. Summary of key concerns and recommendations
2. Economics of RSS
3. Failure of the RSS to tackle climate change
4. Transport
5. Managing the region’s population growth
6. Housing Requirements
7. Water and flooding
8. Waste management
9. Tourism
10. Casinos

1.0 Summary of key concerns and recommendations

In summary our key concerns and recommendations are :

1.1. The objectives of the Draft RSS, “What Sort of Region Do We Want To Be?”, are focused entirely upon development and economic growth, with little emphasis on quality of life, the reduction of poverty, equality, or creating a sustainable footprint.
 
1.2. We believe the Draft RSS is flawed by being based upon a model and prediction of economic growth which has not assessed significant likely changes in factors during the next 20 years. Its perspective needs to be rethought, and additional plans developed that take account of different economic forecasts.

1.3. The SSA concludes that the Draft RSS is quite inadequate in addressing the subject of climate change. While noting some significant steps forward, the SSA judges its objectives to be unlikely to reduce greenhouse gas emissions. A more immediate and radical approach is the only acceptable strategy.

1.4. We support the SSA’s proposal that the South West should be “less dependent upon its national and international links”. This approach would bring the most economic and environmental long-term benefits to the region.

1.5. Our view is that the airport development proposals in the RSS must not go ahead. The SSA concludes that if they do, “all other gains in CO2 emissions will be cancelled out by growth in air traffic alone.”

1.6. Other issues covered in our submission include the need for more affordable housing, a more sustainable approach to growth and development, a rethink on SSTCs, better public transport, more renewable energy, better management of waste, research into tourism benefits and opposition to a casino.

2.0 Economics of RSS

2.1 The RSS economic forecast is badly flawed

2.1.1 Economics are unpredictable

The Draft RSS is based upon forecasts of relatively high-growth scenarios (RSS 8.1.4). The report acknowledges that there are uncertainties surrounding its economic forecasts. Clearly there are a huge number of factors, including geopolitical turmoil, natural and man-made disasters and the growth of countries like China and India that cannot be fully predicted. However, we consider it a fundamental flaw in this plan not to have fully considered other economic scenarios. Very worryingly the SSA notes that the Draft RSS is “highly unlikely” to “reduce non-renewable energy consumption and greenhouse gas emissions.” (SSA Table 6.1, page 95).

2.1.2 The significance of Peak Oil and other options

The Draft RSS notes the need to follow “a low carbon and low resource consuming approach” (RSS 2.3.4), stating that factors such as “the price of fuel...will be important ‘shapers’ of the region” and that in many cases these factors “will have largely unpredictable effects into the longer term” (RSS 2.3.1.). This recognition is welcomed, but the proposals to put this approach into practice are wholly inadequate and entirely too nebulous. At the very least we would expect a more wide-ranging and perspicacious analysis of the effect of the rising energy prices which could have such a huge impact on our region.

One key scenario missing from the report is that of Peak Oil, the point at which oil production rises to its highest point before declining. Almost all expert opinion already agrees that it is fast approaching and will possibly arrive within five years, and almost certainly within fifteen. The significance of Peak Oil can hardly be overstated; oil is the fundamental underpinning of our economy. When the oil runs out the economic and social dislocation will be unprecedented. We are very concerned that long-term global policymaking on this aspect, perhaps the biggest decision this century, appears to be virtually non-existent and is driven instead by the lure of a short-termism that is highly destructive. The Swedish government is an exception in that it has already launched a programme to end Sweden’s oil dependence by 2020. In the light of Peak Oil, many aspects of the Draft RSS will need greater consideration.

It has taken 145 years to consume half the conventional oil supplies, and it is expected that the other half will be largely consumed within just the next 40 years. In 2003, major oil field discoveries fell to zero for the first time, and the excess capacity held by OPEC nations has dwindled from an average of 30% to about 1% of global demand now. Figures show that world oil and gas production is declining at an average of 4%-6% a year, while demand is growing at 2%-3% a year. President of Exxon Mobil Exploration, John Thompson, said in 2003, "By 2015 we will need to find, develop and produce a volume of new oil and gas that is equal to eight out of every ten barrels being produced today." But oil on that scale is just not available.

Then what are the options left to us ? The US is pursuing by force of arms the lion's share of what oil remains (see note 1). Others are considering shifting to unconventional sources of oil like tar sands and gas to liquids processing. But the vast environmental costs of these processes, along with their financial expense, make this prohibitive (see note 2).

This leaves just one option that is both realistic and desirable - to move quickly towards renewable sources of energy, like wind power, biomass, tidal power and solar, while at the same time reducing energy demands. While we applaud the Draft RSS for recognising the requirement for expansion in renewables, the need is for a substantially greater and much faster switch to this option.

Peak Oil not only represents a danger but creates opportunities for the region, if properly planned for. But in order for these to be realised, many aspects of the RSS will need greater consideration. For example, we disagree that in the future “less land is likely to be used primarily for food production” (RSS 7.3.16). If oil prices rise as predicted by some then this will make the transportation of food (including flying) over long distances more expensive. We can envisage more food being grown locally in the longer term. A report by Lang, Ball, Morison and Pretty, “Farm Costs and Food Miles: An assessment of the full cost of the UK weekly food basket”, argued that food could only be called sustainable when it is grown and consumed within a 20 mile radius. Similarly, moves towards greater organic farming will be more necessary and desirable compared to energy-intensive pesticide, herbicide and fertiliser farming (see note 8). The South West already has the largest portion in the country of organic agriculture, with 900 organic farms (21% of the UK’s total). This is something we should be aiming to build upon and increase.

2.1.3 Conclusions

We consider it a fundamental flaw in this plan not to have fully considered other economic scenarios and to have included the possibility of those within the RSS. There is currently little room for manouvre to adjust the RSS if economic forecasts should change. The RSS must take account of the likely energy price rises by moving with far more urgency towards a low carbon economy.


2.2 Adopting an alternative approach to the region’s development

2.2.1 An alternative approach

We recognise that the aim of the draft RSS is to develop the economy within environmental limits and the uncertainties outside of the control and influence of the South West. To that end we welcome the SSA urging consideration of an alternative to the Draft RSS be considered - an alternative that examines in detail “an approach to development and activity in the region that is less dependent upon its national and international links, and footloose investment”. The SSA goes on to note (SSA 8.24), “This could help reduce its exposure to external factors, making it more resilient to outside shocks, and at the same time reduce its ecological footprint. Whilst this would go against the grain of current thinking, it may offer alternative sustainability advantages that have not yet been explored.”

2.2.2 An example of challenges ahead : ‘bra wars’

The challenges facing us on textiles last year illustrate our concerns. The so-called 'bra wars' with China are just the tip of the iceberg. There are those who believe that Chinese competition presents no threat to Europe on the grounds that we can give up what is left of our older manufacturing base, and concentrate instead on knowledge-intensive industries. But this is simply a denial of the facts. China, and indeed India, are fast developing their own low-cost but highly skilled expertise in these areas too. 20% of China’s exports are already ‘high tech’, and with two million Chinese graduates a year there is every reason to believe that this percentage will increase. The threat from such competition will spread to other sectors of the economy, as suggested by  the Draft RSS (RSS 2.3.5) and the economy of the South West will certainly not be immune.

The Draft RSS suggests we should “raise productivity”, but the free trade model simply isn’t working. Chinese costs are artificially low because of the country’s appalling record on the environment and the failure to protect workers from exploitative pay, long hours, and industrial accidents which result in around 100,000 deaths every year. Meanwhile there are over 100 million Chinese living on less than a dollar a day. It is quite obvious that we cannot compete on this inequitable and unjust playing field.

The textiles crisis should be a wake-up call to the true costs of free trade and the risk this poses to the economy of the South West. The Green Party argue that we must build a trading system based upon high social and economic standards, with quotas where necessary. This would be both fairer and more sustainable for workers everywhere. It would also lead to the approach hinted at by that of the SSA, one in which localisation is prioritised over globalisation, thus benefiting local communities and the environment.

It is not the place of this submission to argue about the details of the national and international laws necessary to build a trading system. However it is necessary to:

- raise our concerns about the impact our current economic model will have on the region

- consider what steps need to be taken in the South West to minimise adverse impacts from the contradictions within the existing model, particularly those noted by the SSA.

2.2.3  Relationship between consumption and happiness

We welcome the discussion and recommendations in section 4.33 of the SSA regarding the relationship between happiness and consumption. It notes, “There is no evidence that the UK pattern of economic development is making people happier or giving them a better quality of life.” But we believe it is vital that indicators for measuring happiness are developed and  implemented as part of policy.

2.2.4. Conclusions

- We consider that it will be in the best interests of Stroud District for the RSS to adopt the alternative approach to the region’s development as suggested in the SSA.


2.3 Economic growth and SSCTs

2.3.1. Wrong approach

The Draft RSS appears to have an unsophisticated approach to 'economic growth', which fails to distinguish between dissimilar types of economic growth. This is particularly in regard to who will benefit from different types of growth, the different spatial needs of different types of growth and differences in sustainability of different types of growth. Thus allocating the majority of growth to Strategically Significant Cities and Towns (SSCTs) does not really make sense until this differential analysis is done.  A major failure of the RSS is that it concentrates on identifying where economic growth should happen. In our view this is simply 'business as usual’, and the opportunity to address the more substantive issues of what type of growth and for whom (Draft RSS Development Policy A).

In fact, a larger issue is not about growth per se. It is about managing the economic change that is necessary to move towards sustainability and meeting the welfare needs of the population in a very different world economic environment in 2026.  This is far from being adequately addressed in the Draft RSS. The RSS considers how existing economic activities can grow with minimum detrimental environmental and social damage,  and concludes they need to be concentrated in the SSCTs. However, it fails to consider the opportunities for promoting different economic models. This includes, for instance, increased remote working using information and communication technology (ICT) which may mean that more balanced and dispersed development, with smaller nodes, is both more sustainable and more equitable.

2.3.2. Out-commuting

The RSS identifies a key problem of 'out-commuting' in towns like Stroud. The solution in the Draft RSS is to develop more employment in Stroud (RSS 4.2.45).  This solution is based on a misdiagnosis of the cause of the problem.  It is not lack of employment in itself that is the problem in the Stroud area, as the low unemployment figures there show. The cause is partly a lack of certain type of jobs in Stroud and also that many people who work in surrounding cities choose to live in Stroud.  Undifferentiated development of jobs in Stroud does not necessarily result in less out-commuting; it can also result in two other things:

- In-commuting of workers from areas of less expensive housing (eg., parts of Gloucester).

- In-migration of people from elsewhere in the UK or the EU to take up the jobs that are not filled by those already living in Stroud. This further exacerbates problems with housing supply by putting further pressure on affordability.

2.3.3. Conclusions

It is evident that just “providing more jobs” is insufficient (RSS 4.2.45), and more advanced and clearly considered policies are needed to create  more localised and sustainable economies and communities. 

3.0  Failure of the RSS to tackle climate change

3.1 Can policies be delivered ?

We applaud the steps forward that have been made to improve sustainability, and in particular we agree with the SSA that, “Policies SD1 to SD4 provide a very sound…..basis for putting the South West on a more sustainable path.” (SSA 7.11). However, the SSA also notes in the same section, “The main issue will be delivery. The policies set down some tough challenges, which will be difficult to achieve given the scale of development proposed over the plan period, and the stubborn unsustainable trends, particularly with respect to resource consumption which have led to the region’s ecological footprint being unsustainable on current trends. For example, policy SD2 recognises the importance of climate change as the greatest threat facing life in the South West, but evidence suggests that the region will be unlikely to achieve the targets set in the policy without in particular a major shift in transport behaviour and much higher performance in energy efficiency across the domestic, industrial and commercial sectors.”

Other groups have raised similar concerns. South West Friends of the Earth (FoE) write in their briefing: “The RSS itself acknowledges that unless it puts ‘sustainable development at the heart of the strategy, growth has the potential to erode the very quality of life that makes the region distinctive’. Despite the strong statements of principle, there is much in the Draft RSS that gives cause for concern, and suggests that growth will lead to degradation of the environment, growing emissions (from transport in particular) and a reduced quality of life for many people across the region.”

3.2 Greenhouse emissions set to rise

The Government now accepts that Britain is unlikely to meet its own domestically set targets of cutting emissions by 20% below 1990 levels by 2010. The SSA (page ix.), notes in its “Summary of likely sustainability effects of the draft RSS”,

- “An increase in greenhouse gas emissions, despite strong policies on energy efficiency, as a result of increased traffic and air travel.”

- “The actual amount of travel by car is likely to increase.”

- “The overall effects on greenhouse gas emissions of the approach to high economic growth and connectivity do not appear to have been considered.”

Finally, it states that the Draft RSS is “not clear” about how the need to reduce climate change influenced the strategy (SSA Table 6.1, page 79).

3.2.1 New developments

Policy RE5 of the Draft RSS requires all new developments of 10 houses or more to reduce their CO2 emissions by a minimum of 10% through the provision of on-site renewable energy generation. For larger developments, Development Policy G specifies that they should be “carbon neutral”. Taken together, these policies mark a radical shift in the energy standards of buildings in the South West and would contribute significantly to carbon reduction targets. In addition, Policy RE5 would stimulate a boom in domestic scale renewable energy and energy efficient measures, such as heat pumps, micro Combined Heat and Power boilers, solar hot water, space heating and electricity. The implementation of this policy would therefore have widespread economic benefits.

We agree with FoE and others who strongly support these policies, but also argue that the proportion of energy from renewables could be progressively raised to more than 10%.

3.2.2 Renewable energy targets

The South West has the second highest household electricity consumption rate in Great Britain (see note 8). Currently only 3% of the region’s electricity consumption comes from renewables. 35% is from wind power, 7.5% hydro-electricity, 47% landfill gas, 8% sewage gas, 2% advanced treatment of waste and under 0.5% from photovoltaic solar electricity (see note 8). Regen SW (2006) note that, “The region is making very slow progress towards its 2010 renewable energy target of securing 11-15% of generating capacity from renewable sources…..We will miss this target unless the rate of construction increases.” (See note 8).

Policy RE1 sets targets for renewable electricity generation in the South West in line with Government targets. These are for at least 10% of the region’s electricity consumption to come from such sources by 2010, and 20% by 2020. However, other regions are now setting more ambitious targets than those set by central Government and in our view it is quite wrong for the South West, with some of the best renewable energy resources in Europe, to have one of the lowest targets.

3.2.3 Conclusions

We cannot overstate the importance of our concerns that the Draft RSS will lead to an increase in greenhouse gas emissions. This increase will have huge impacts on our environment and our economy. In our view this is unconscionable and it is essential that the extent of its potentially damaging effects is fully recognised. The SSA identifies transport and higher performance in energy efficiency across the domestic, industrial and commercial sectors as two key aspects (SSA 7.11). Both of these require greater consideration in the RSS along with the other measures mentioned, and the reduction of waste and unnecessary consumption.

4.0 Transport

The Green Party view the proposed expansion of aviation in the region as so important and alarming that we have produced a separate section outlining not just the environmental impacts but also those which are economic and social (see sections 4.2.1- 4.2.6 below).

4.1 The approach to transport

4.1.1. Key concerns

The Environment Agency reports that the South West has the highest number of journeys made by car, the second highest increase in traffic volume and some of the least accessible bus services in England. In addition, the average person in the South West travelled 7,919 miles in 2003-4, more than in any other region and significantly higher than the English average (see note 8).

We would expect a twenty-year guide on transport to be more ambitious in its environmental aims, especially with regard to the reduction of congestion and CO2 emissions. But the whole approach of the RSS is far too timid on these issues, and fails to set any tangible targets. We therefore feel that the present Spatial Strategy will not succeed in cutting traffic movements, especially with inward migration proposals. The document should be clearly indicating the method of progressively reducing carbon use. This would be in line with the Government’s official climate change objectives; namely to make a cut of 20% of CO2 emissions from 1990 levels by 2020. By the year 2050, the Government accept a 60% reduction is required to maintain a stability of a 2-degree temperature increase at the current level. Scientists are now arguing that this is an underestimate of what is needed and considerably larger cuts are needed.

Figures released from the EU suggest that CO2 emissions are still increasing despite the agreed programme. In this country 24% of carbon emissions come from transportation movements, and the RSS proposals will not produce the desired changes.

Friends of the Earth say, “Whatever debates may rage around the correct scale of housing growth across the South West, it is clear that transport is a key to determining whether or not growth is within environmental limits - and particularly the need to get carbon emissions on a sustained downward path. The Draft RSS acknowledges that past patterns of development are flawed and that there is a need for a “step change” in the quality of our urban living and public transport provision. FoE believes that for all its good intentions, the transport chapter of the Draft RSS is too beset with weaknesses and inconsistencies to achieve its aims. There is no overall aim to reduce traffic, and the high levels of investment proposed for roads would continue to fuel the growth in the number and length of car journeys.”

The RSS is quite correct in saying (5.1.2) that any improvement to strategic road routes will increase the volume of traffic flow, so in reality these kinds of schemes should be limited to the absolute minimum. Making the car journey more easy only serves to generate more traffic. We approve of the strategy which looks at the region in terms of sub-divisions, in so far as it should make these sub-areas more sustainable, and the need to travel beyond them much less advantageous or worthwhile. On a micro-scale within these sub-regions we need to ensure that towns are in themselves much more sustainable. This idea should include people sourcing local food and goods wherever this is possible.

We also have concerns that there is inadequate reference to how new infrastructure will be funded/provided to help accommodate and assimilate the proposed levels of potential growth. There is a need for co-ordinated funding support from central government to assist with timely provision of relevant infrastructure to meet transport, education, health needs etc that will arise out of such levels of growth. Even to continue RPG10 levels of growth will present significant challenges in itself.


4.1.2. Alternatives to the  private car

One of the key areas where the RSS falls down, is in that there are no proposals for more major integrated public transport systems, and no major improvements to our rail system. Our current rail network has been in existence for over 150 years, and with our dwindling oil supply and CO2 emissions it is necessary for an increase in the number of lines across the South West and the doubling of capacity of our current lines to be planned and endorsed. However, it is also clear that only a drastic reduction in fare rates together with increased reliability will make the public leave their cars at home.

Another example of good practice that is exploring alternatives to private car ownership are Car Clubs. The Government, via the Countryside Agency, has piloted a number of Rural Car Club schemes in the South West over the past four years. These pioneering Clubs have raised awareness of the ever-increasing private ownership of cars (more families now own two carsthan those who own none.) Research proves that each Car Club car takes 6 privately owned cars off the road. The scheme provides access to cars with low emissions and effectively makes users plan ahead and choose the mode of transport, whether it is walking, cycling, taking the bus or train or lift-sharing, and only after these to consider the use of the car. Carplus, the Car Club network, say, “We promote responsible car use primarily through developing car clubs and car sharing within an integrated sustainable transport framework. Carplus use cars to reduce car use – and hence greenhouse gas emissions – through encouraging and facilitating behavioural change in personal transport.”

4.1.3. Freight

It is also essential that movement of freight from road to rail is made a priority with the incentive of making it economically attractive. In addition, there is no reason why on both national and international levels a greater proportion of our freight should not be moved more by cargo ships around our coast.

We fully endorse all the proposals in the SSA 11.28, that only through Government policy will we be able to steer through a lot of the RSS’s sustainable initiatives. However, the real test is whether the Government will introduce a carbon tax for both industry and the public - without this it will be difficult to reach either national or regional targets.

4.1.4. Conclusions

The Draft RSS acknowledges that past patterns of development are flawed and that there is a need for a “step change” in the quality of our urban living and public transport provision. The Draft RSS fails to do this.

4.2 Airport development proposals must not go ahead

4.2.1 The Draft RSS is deliberately misleading

The Draft RSS argues that there will be “some sustainability benefits” from reduced road travel to Gatwick and Heathrow (Draft RSS 5.4.12). However, as pointed out in the SSA, this is quite misleading (SSA 11.19 and 11.20). We find it extraordinary that the Draft RSS could make such claims that are completely at odds with the facts, and we can only conclude that this is a weak attempt to try and defend an insupportable policy. As the SSA notes,

- “Climate change impacts of surface transport per passenger kilometre are lower than air travel, so for climate change it is better for people to do as much as possible of their journey by surface before flying.” (SSA 11.19).

- “Government policy is not to displace flights from other regions, but to increase capacity both in and outside the South East. Therefore increases in the South West will not displace flights from the South East, but will create space for further overall expansion.” (SSA 11.19).

4.2.2  Forecast growth is nonsensical

The forecast growth from 4.5 million passengers per annum in 2000 to almost 20 million by 2030 is absurd in the light of forecasts regarding oil prices and other environmental and economic considerations.

The South West has seen rises in air travel higher than the English average (see note 8), but as with the national picture much of the current aviation growth is not based on ‘need’ but on artificially inflated demand. The five-fold growth of passenger movements in the past ten years is the result of an artificial and unsustainable bubble brought about by discounted fares from budget airlines. The aviation industry has benefited from cost subsidies in the form of tax exemption on fuel and total exemption from the need to contribute to local interests such as infrastructure and public transport.

4.2.3 Climate change; the airport will undermine efforts in all other sectors

The SSA says, “The RSS should explicitly resist airport expansion, because it would undermine all the efforts within other sections of the draft RSS to reduce greenhouse gas emissions.” (SSA 11.20 in the response to RSS TR9).

Aviation is responsible for the fastest growing source of greenhouse gases, with emissions from air traffic doubling since 1990 and set to quintuple. Yet the Department for Transport does not require BIA or any other airport to take climate change into account when expansion is proposed. It is vitally important to remember that trains are 19 times more carbon efficient than planes, while at the same time 70% of EU flights are short haul journeys of less than 1000km. The consequence of this disparity in carbon emissions between planes and trains cannot be overstated, nor must it be overlooked. With trains now capable of travelling at 300kph, we should be looking not towards airport expansion but towards the growth of a fast rail network. The SSA states, “To be more sustainable, improving connectivity should focus attention on significantly improving rail links rather than the road network, as currently the policies in Section 5 will result in increased car use and greenhouse gas emissions.” (SSA 11.23).

The Government has set a target to cut emissions by 60% by 2050. If aviation emissions continue to grow at the current rate it will be virtually impossible for the 60% target to be met. Improvements in aircraft technology can only deliver 1% a year cuts in emissions, so allowing a maximum passenger growth of 1% a year would be needed even just to stabilise emissions.

4.2.4 Aviation subsidies damage the economy

The expansion of the airport will be heavily dependent on public subsidy through the provision of infrastructure to serve the airport, and through many tax incentives that give unfair advantage to aviation over other more sustainable transport providers. It would not make sense to base plans on expansion on the unsustainable use of these incentives, which should be removed within the lifetime of these proposals.

The recent FoE report, “Why airport expansion is bad for regional economies” makes a strong case that needs answering (see note 4). The UK already runs a massive economic deficit from air travel. Foreign visitors arriving by air spent nearly £11 billion in the UK, but UK residents flying out spent £26 billion abroad, representing a loss to our economy of £15 billion. FoE estimates that airport expansions in the South West will lead to a massive £30 billion currency outflow between 2004 and 2020.

4.2.5 One Planet living unachievable with airport expansions

We welcome the Draft RSS’s acceptance that the South West’s ecological footprint is unsustainable as it stands. It notes the need to shift from our current ‘three planet’ lifestyle to one where we consume resources compatible with one planet (RSS 1.6.2). RSS SD1 specifically states that the region’s ecological footprint will be stabilised and then reduced by “Requiring a shift towards the more sustainable modes of transport.”

From looking at Bristol we can see that BIA’s Master Plan for access to the airport is wholly inadequate to deal with the additional numbers travelling to the proposed airport expansion. Promoting connections to motorways will continue the trend of car reliance and the negative social and health impacts related to this. However, far more damaging is the significant increase in proposed flights. As noted above, the expansion of airports would undermine all the efforts within other sections of the Draft RSS to reduce greenhouse gas emissions. Expanding the airport will lead to an increase in consumption of natural resources, thereby increasing the region’s ecological footprint - in direct opposition to the Draft RSS’s stated aims.

4.2.6 Other factors

We agree with the SSA that we need an introduction of fuel tax on aviation fuel, as well as emission charges and increased landing charges on aircraft. It is known that oil demand will very soon outstrip supply, yet this most significant factor has been left out of the Government’s plans for expansion and the Draft RSS.

Aircraft engines emit various pollutants including nitrogen oxides and particulates, which have significant damaging impacts on human health and on natural ecosystems. Aircraft noise is also a serious health issue for those living close to airports and flight paths.

If job creation is one of the objectives behind support for the expansion, we would argue that more sustainable sectors of the economy could provide far greater numbers of jobs. The SSA notes, “Airport development may generate jobs during both construction and operation, and may help to support sub-regional economies, but the effects of air travel on the climate is so significant, that this approach to economic development should be considered to be unsustainable.” (SSA 11.20).

Domestic spending abroad already accounts for 83% of tourism spending; if more people travel abroad then the amount they spend here will be reduced.

Finally, there is a lack of any objective analysis in the Draft RSS of how expansion compares with more sustainable ways of improving the local economy and environment, and with alternative means of transport provision.  Meanwhile, the SSA states, “Other forms of economic activity, that are not dependent upon or that encourage air travel, whether for business or leisure, should be pursued.” (SSA 11.20).

For a more detailed analysis of the effects of the airport expansion, see note 3.

4.2.7. Conclusions

Climate change is the greatest environmental and indeed economic challenge facing the world. The airport expansion runs counter to any long term view of economics or sustainability. The FoE briefing on the RSS states, “Perhaps the greatest contradiction in the transport chapter of the Draft RSS is the support which is given to air travel - the most polluting form of transport. The excuse for this is that it is required by Government policy, but Government policy also requires the South West to implement sustainable development, and if the two policies are in conflict the region’s planners should not be afraid to point this out.”

We agree with the SSA report and support it in the strongest terms when it states in its conclusions, “Withdraw the airport development proposals included in the Aviation White Paper since all other gains in CO2 emissions will be cancelled out by growth in air traffic alone, and introduce fuel taxes that reflect the environmental cost of air travel.” (SSA 11.28).

5.0  Managing the Region’s Population Growth

5.1  Stabilising population growth

The Draft RSS follows a ‘predict and provide’ approach to population growth and housing provision instead of addressing strategies required to achieve a stable and sustainable population and affordable housing.

Annual population growth here is above the English average. By 2028, the South West’s population will have grown by 16%, the second highest increase in the English regions (see note 8). The Draft RSS talks about harnessing the benefits of population growth (RSS, Chapter 6). But what is missing is active and urgent debate about suitable population levels for different regions of the UK which also considers levels of consumption, material comfort and sustainability, including the UK’s impact on the rest of the world.

Development in the country is skewed towards the South East, and to a lesser extent towards the South West. We urgently need to review this and develop policies for more balance across the whole country. Talk of moving water from the South West to the South East should alert us to the fact that we should be tackling the causes of the problems and not just the symptoms.

As the Draft RSS points out, we need to reduce our ecological footprint; how much we consume will determine the amount of space we utilise. Yet the Draft RSS looks set to fail to reduce the footprint - even if we reduce consumption significantly, we still have a problem if numbers keep increasing.

5.2 Scale and location of growth

5.2.1. Green Infrastructure Planning

Given the likelihood of new development in the South West, it is important to consider not just where it takes place but how it is planned and implemented. Green Infrastructure Planning provides a means of planning developments that are both wildlife and people friendly.

Green Infrastructure (GI) consists of a network of linked green spaces, which meet people’s needs for recreation and quiet contemplation and encourage green transport modes such as cycling and walking, whilst also providing habitats and movement corridors for wildlife. As it is difficult to fit this sort of network into existing or planned networks of grey infrastructure – like roads and utilities - it is important that GI is planned before or concurrently with the grey infrastructure (see note 9).

We welcome that the Draft RSS for the South West recognises the importance of GI to new and existing development. It defines GI as follows :

“Green Infrastructure is an important component of ensuring development provides positive benefits for the region. GI consists of strategic networks of accessible, multifunctional sites (including parks, woodland, informal open spaces, nature reserves and historic sites), as well  as linkages (such as river corridors and floodplains, wildlife corridors and greenways). These contribute to people’s well-being, and together comprise a coherent managed resource responsive to evolving conditions.” (RSS, page 137).

The SSA also notes (9.6), “The emphasis on green infrastructure is likely to be beneficial to biodiversity, landscapes and townscapes”, and (12.5) “Cycling and walking should be made easier and more attractive through the development and management of Green Infrastructure.” If the suggested policy on GI is eventually included in the approved RSS, it will require a new emphasis on GI to be incorporated into the Local Development Documents produced by the local authorities. The RSS (page 43) states, “Local authorities should work closely with landowners, developers, stakeholders and service providers to achieve a master plan…. Master plans should also ensure provision of sufficient amenity space and green infrastructure to enhance the living environment and support improved biodiversity.”

5.2.2. Development and sustainability

The Draft RSS recognises the need for more people to live where there is access to easy public transport or within walking or cycling distance of key services and jobs. It then makes a leap in assumption that the majority of new population growth should be within and on the fringes of the SSTCs. This is a dangerous over-simplification.  Smaller settlements can be sustainable - and need to be made and kept sustainable - by the maintenance of rural services and public transport.  Some small towns can be more sustainable than large cities.  The key therefore is not getting everyone to live in cities, but in developing sustainable links between where people live, services and jobs. There is far too little emphasis on this in the Draft RSS. The current  moves towards the centralisation of health services, with the  threatened closure of health services in Stroud and relocation to Gloucester and Cheltenham, is an example of policies that are likely to reduce the quality of life and sustainability of a large number of people in the Stroud area.

What tends to be unsustainable is suburban sprawl, whether on the outskirts of a big city or the outskirts of a market town.  This is a challenge that is not fully addressed in the RSS, as many people quite understandably aspire to a 'house with a garden'. This is also the type of development currently considered most profitable by many developers.  The draft RSS talks about 'good design' helping to encourage people to live in urban areas and accept higher housing density levels, but fails to develop this fully.  Actually, evidence from the UK and Europe (see ‘Cities for a Small Country’, Rogers and Power, 2000) shows that high density can be highly desirable. But it does require good design. This is crucially important not only for the housing itself, but also the public space around and between the high density housing, such as local shopping areas, playspace, parks, green pockets, attractive streets, allotments and accessible countryside. This can be a feature of desirable high density development not only in the 21 SSTCs, but also many smaller market towns. Some of the threats to the Green Belt implicit in the Draft RSS would be totally counter-productive in creating this desirable living space, and some previously developed land needs to be redesignated and managed as public open space in order to achieve this.

5.2.3. SSCTS

We do not consider SSCTs as a useful model for developing the region. We therefore could not support Stroud being designated as a SSCT. It does not have the capacity to absorb any strategic levels of growth in a sustainable manner, particularly housing, that befits a SSCT. In addition, as noted (see section 2.3.), there are already strong commuting patterns between Stroud and the nearby SSCT’s of Gloucester, Cheltenham, Bristol and Swindon. Further significant housing development at Stroud is likely to increase those movements and be unsustainable.

5.2.4. Conclusions

The concentration on locating additional housing in the 21 SSTCs (Development Policy A) is not helpful.  For the reasons of sustainability and quality of life there should be much greater emphasis on:

- Stabilising the population in the SW.
- Improving local access to services and jobs to enable a sustainable and good quality of life for the existing population - not just for new developments in SSTCs.
- Applying sustainability criteria to all new development - wherever located (SSTC, market and coastal town, village or hamlet).
- Applying Green Infrastructure planning to all development and redevelopment.
- Ensuring sufficient emphasis on high quality public open space around existing and new higher density development.
- Ensuring high quality green space and countryside is within reach of all living areas.

6.0. Housing Requirements

6.1. Proposed levels

In the Draft RSS the Stroud District provision for the 20 year period is:

Existing commitments south of Gloucester        100 p/a or 2,000 dwellings
Elsewhere in Stroud District                         235 p/a or 4,700 dwellings
Total provision for Stroud District                 335 p/a or 6,700 dwellings

The housing requirement for Stroud District as expressed in the Draft RSS is higher than we consider sustainable and we would be concerned if this requirement were to rise.

We are also concerned about the quality of existing stock, particularly relating to energy efficiency. Gloucestershire also has an estimated 3000 households living on overcrowded conditions.


6.2. Affordable housing targets

We urge that much higher targets for affordable housing are made for all housing developments, with the 30% figure in the Draft RSS rising to 60% or higher to make a good start. However, we agree with the SSA report and its concerns that the targets for affordable housing and densities within development proposals are likely to be very difficult to achieve “without the provision of some public subsidy” (SSA, 12.25). The SSA (17.1) also states that “The extent to which ‘everyone’ will have access to suitable and affordable housing is difficult to assess”, and (12.9), “The main uncertainty is tying in delivery of affordable housing with funding and economics of development. Aspirations are high in Policies H1 and H2, but it is not clear whether there is the public funding in the right places to deliver and/or what can be achieved without grant.”

We welcome the awareness shown in the RSS (6.1.6) when it says, “Careful attention needs to be given to the housing affordability problem in rural areas. Experience has shown that, simply building higher levels of market housing often attracts more commuters, second home owners or retired people from outside the region.” However, the SSA (9.12) highlights the inadequacy of the proposals in the RSS, saying, “Affordable housing is often likely to be as important as economic development in many smaller towns and villages. Although affordable housing is mentioned in the supporting text, it is not explicitly mentioned in Development Policies B or C. Housing is not mentioned at all in Development Policy B. Because large parts of the South West fall outside the sub-regions in Section 4 of the draft RSS, it could be questioned whether the draft RSS is as clear as it could be about how to plan for the rural parts of the region, and it could say more about how their characteristics vary across the region.” In the SSA’s assessment of “Aspects that could be improved” (15.7), mention is made that “Affordable housing should also be a key part of the urban economic development, regeneration and neighbourhood renewal approach”. We believe that more emphasis should also be given to the notion of quality of life with regard to affordable housing. There should be more stringency on planners to ensure that the concept of regeneration is not limited to the merely tangible aspects of the decision to live in the region.

6.3. Second homes

Every purchase of a second house deprives someone else of a first one. Insufficient attention has been paid in the Draft RSS to the need to restrict the growth of second home ownership - currently 3% per year. This issue is recognised in the Draft RSS at various points. However, there is no policy approach to helping resolve the problem.

In England and Wales there are 250,000 second homes. In England there are 221,000 people classed as single homeless or living in hostels or temporary accommodation. These cases comprise about 24% of those in need of social housing. We are not arguing that if underused houses were turned back into a home the problem of acute homelessness would be solved. But we are arguing that homelessness has been exacerbated by the government's failure to ensure that houses are used for living in.

We consider there is merit in exploring ways to curtail second-home ownership. Some commentators suggest a 500% council tax for all second homes, which local authorities are obliged to use for new social housing.

6.4. Conclusions

The inadequate and inequitable provision of housing in this country is the result of inequalities in access to resources, especially land, the inability of the free market to meet diverse housing needs and a lack of investment in public housing spanning over two decades. To eradicate these inequalities it is essential to bring housing policies under local participatory democratic control.

We would wish to see a balanced mix of housing tenures to meet the diverse needs of communities. These include individual and shared home ownership, leasehold and others. Disincentives to the speculative ownership of housing should be introduced, including higher rates of Council Tax for unoccupied properties and second homes. People must not be forced into home ownership because there are no alternatives for them. We would also seek to increase the amount of social housing and commonly owned housing as representing the best way of ensuring an availability of affordable housing. Targets for affordable housing must be supported by proper funding.

7.0 Water and flooding

7.1. SUDS needs prioritising

The importance and benefits of Sustainable Urban Drainage Systems (SUDS) are huge, and could be more emphasised in the Draft RSS. The benefits listed by the “Interim Code of Practice for Sustainable Drainage Systems” (July 2004) which was compiled by the National SUDS Working Group and published by OPDM and Defra, include:

- Reducing peak flows to watercourses or sewers and potentially reducing the risk of flooding downstream

- Reducing volumes and the frequency of water flowing directly to watercourses or sewers from developed sites

- Improving water quality over conventional surface water sewers by removing pollutants from diffuse pollutant sources

- Reducing potable water demand through rainwater harvesting

- Improving amenity through provision of public open space and wildlife habitat

- Replicating natural drainage patterns, including the recharge of groundwater to ensure that base flows are maintained.

We welcome the recognition of the need for water conservation measures and sustainable drainage systems in all development through supplementary planning guidance (RSS, 7.3.14). Stroud District Council have already adopted a SUDS approach in their Local Plan, but many areas are not implementing best practice. We regret that in the Draft RSS, SUDS do not appear to have been incorporated into Policy RE6. This is of particular importance when there are instances such as Severn Trent region’s 4% annual rise in land being given over to hard-standing.

Climate change will bring about many additional stresses on our water systems, and it is vital that we take advantage of the flood and pollution controls and the wider enviromental benefits of SUDS. Othe conservation measures like the use of grey water should be introduced into all new developments.

7.2 Flood risk developments

7.2.1 Flood risks to increase

The Draft RSS notes that the risk of coastal and river floods will increase significantly over the plan period (RSS, 7.2.19). Beyond that period the rises are expected to be even greater. Indeed, the Environment Agency note that the South West could have potentially the highest increase in sea level rise in Great Britain resulting from climate change (see note 8). Management of flood risk is an important issue, particularly in the light of climate change and a rise in sea levels. Some locations will remain insufficiently protected and this needs further consideration if we are to prevent “significant implications in the future.” (SSA 17.7).

7.2.2 The implications of Policy F1 on nuclear sites
Policy F1 is welcomed. In particular it should rule out the siting of nuclear power stations or nuclear waste depositories along much of the coast in the South West. Nirex, Britain’s nuclear waste management agency, reports in its summary of ‘Climate and Landscape Change’ that seven out of eleven current nuclear reactor sites are not viewed as fit for new nuclear reactors or nuclear waste sites. Four will be vulnerable to flooding and three others vulnerable to coastal erosion. Berkeley and Oldbury are cited as having a “high risk of flooding”, while Hinkley is at risk of “flooding and erosion”.

8.0 Waste Management

8.1 Reduction of waste

Reducing waste in the first place, the most important factor of all, is noted and welcomed but policies to show how this will be achieved are largely missing in the Draft RSS. The SSA stresses this point, saying, “More emphasis on reducing the production of waste in the first instance (e.g. by reducing consumption) would put waste management into the sustainability context of the RSS as a whole.” (SSA 13.36), and notes “The amount of materials consumed in the region continues to increase, as does the amount of waste, despite improvements in recycling.”

We should not forget that in many ways recycling is a failure: crushing, pulping and smelting materials is unnecessary, hugely energy intensive and damaging to our environment. We need to start reclaiming and reusing materials not destroying then reproducing them.

8.2 Waste: which way forward?

The SSA (13.16) notes, “Waste management is recognised …….as one of the greatest challenges facing the region in light of growth proposed in the Draft RSS.” England still has one of the lowest rates of recycling in Europe, with the Netherlands recycling 64% of its waste, Germany 57% and Denmark 41% (see note 8). The South West managed 27% of domestic waste while England’s average was 23%. (see note 8).

We have a choice in this matter. We can either adopt a policy of low levels of recycling with incineration, along with all its damaging effects upon the environment and health, or we can do as the Green Party advocates, encouraging high levels of reuse, recycling and composting with a small remainder of waste for treatment. We would like to see the RSS adopt the greener option. At the very least there should be a phase-out of the disposal by incineration or landfill of any waste that can be re-used, recycled or composted. The SSA goes on to add (13.37), “The policies would be enhanced by recognition of the importance of community based waste management initiatives used to raise awareness of waste management options. These are supported in the Regional Waste Strategy (2003).”

8.3 Radioactive waste

The Draft RSS notes that with regard to radioactive waste they will await the recommendations of the Committee on Radioactive Waste Management (CoRWM). These have now been published and advocate burying the waste deep underground, after decades of interim storage to allow for intensified research to address ‘uncertainties’. We strongly object to the idea of ‘deep disposal’. Nuclear waste must be stored in above ground facilities to allow easy access in the event of something going wrong, and to ensure close monitoring. Burying toxic waste deep in the earth is an unproven, unsustainable and unpredictable route to follow.

In the past we have made miscalculations with the result that some nuclear storage containers quickly fell into a state of serious disintegration. Fortunately those containers have now been refurbished, but this experience clearly indicates the difficulty of assuring the lifetime of waste containers for hundreds of thousands of years when they are deep in the ground. In such circumstances, it cannot be known what geological or climatic changes will impact upon the containers or the waste in the event of further miscalculations or other errors, nor what the scale of any damage to the land or the population might be. There is likely to be a proliferation of geologically unstable countries building nuclear power plants in the future, and it seems probable they would wish to follow Finland’s lead in deep disposal of nuclear waste, not a trend we want further to advance here in the UK. Richard Black, Environment Correspondent on the BBC News website, observes in his article “Time for action on nuclear waste” that “this is clearly an issue which stretches well beyond conventional political timelines; identifying sites for deep disposal and interim storage would only be the beginning of the end.”

8.3.1 Conclusions

It is therefore vital that Policy F1 is taken seriously, and adopted and acted upon. This should mean no nuclear reactors or nuclear waste sites at existing nuclear power plants in the South West.

9.0 Tourism

9.1. Tourism: need for more emphasis on sustainability

We do not consider that enough has been done to move towards tourism being more sustainable. Tourism is one of the key economic sectors in our region, and has a huge impact on our environment and our local economies. If we are to benefit more from this sector, then public transport needs to be prioritised, as it is currently inadequate, unsatisfactory and expensive. Crucially however, while the Draft RSS notes impacts on resources, waste and sensitive environments (1.6.15, RSS), it does not appear to give consideration to the possibility that some communities will not benefit from tourism. Many of us, including most local Councils, seem to be blindly following the mantra that ‘more tourism must be good’.

We urge much greater analysis of the impact that encouraging tourism will have on our local economies. Tourism brought about by the appeal of the area will, for example, lead to an increase in holiday lets and second homes, often pricing out would-be local buyers. The  inevitable impact upon house prices in some areas will be to push them even higher and lead to there being even less affordable housing. This increase, along with greater congestion, will also have a negative impact on local companies who in many cases are already finding it difficult to get workers.

One way forward might be to encourage small, environmentally friendly campsites, similar to the ‘municipal campsites’ found on the edges of many small towns in France. These may be an appropriate way of accommodating increased seasonal numbers of visitors without having a negative impact on housing availabilty.

Many areas in the South West region currently have some of the lowest unemployment levels, so we have to question the wisdom of investing public money to attract more tourists and the accompanying seasonal and generally low-paid jobs.

9.2 Tourism – finding a balance

It is important to be aware of both the good and the detrimental aspects of tourism in the South West. It is not in question that tourism is a key industry here and brings in large amounts of revenue. But while we welcome the benefits of tourism that the attraction of our area brings, the undoubted attractions of the South West region also create certain economic, aesthetic and environmental disadvantages for its inhabitants. The dominant rural nature of the landscape inevitably means that owing to generally poor public transport most visitors will journey here and tour the area by car, adding to air pollution and congestion. The RSS must be made fully aware of “The possible negative implications of encouraging tourism, such as the use of unsustainable modes of travel, and pressures on ….habitats themselves must be taken into account in local strategies.” (SSA 13.33). As tourists never spread evenly through a region, but tend to congregate in particular beauty spots, localised areas become over-visited and these areas are often damaged along with the surrounding environment. Tourism pressures on sensitive environmental areas need to be managed so as not to exceed the capacity of the area, while all businesses stand to gain from a South West region where tourism is truly sustainable. We welcome the SSA’s (14.25) recommendations to the Draft RSS Policy TO1, which advocate the following :

- “Promoting fewer, longer visits, rather than frequent, short breaks.

- Promoting closer markets (i.e. appealing to the local resident market).

- Coming by sustainable transport modes (i.e. sea, rail and cycle/pedestrian travel needs to be more ‘joined up’).

- Travelling while in the SW by rail, bus, bike and on foot.”

9.3. Conclusions

The Green Party are not saying “no” to tourism. As has been noted, it makes a valuable contribution to the good of the region in a variety of ways. In addition, the very fact of people holidaying in the South West reduces the number of those choosing to travel further afield. However, as the SSA (14.22) points out, “Tourism does…. bring pressures”, and we would like to see a more thorough and incisive analysis carried out in order to assess the wider impacts of tourism, and both its positive and negative aspects in regard to our region.

10.0  Casinos

10.1 Negative impacts

We agree with the SSA (14.27) when it states that: “The SSA has examined research undertaken in both the US and the UK, which has found that the negative impacts of a new regional casino are likely to be significant, and are likely to outweigh any benefits. Evidence in the US suggests that casinos cause significant increases in crime. Research in the UK indicates that :

- The social costs of regional casino development are potentially high and, for most locations would outweigh any economic benefit.

- Proposed regional casinos will, on balance, undermine Government targets on neighbourhood regeneration.

- Whilst significant jobs will be created by a casino, both long and short-term, many of these jobs are likely to be displaced from elsewhere in the leisure sector, that they may not match the needs of the local population, and there is strong evidence to suggest that many of the jobs will go to migrant workers.

- It is unclear how much spend will be retained locally, as any tax gains will be distributed nationally rather than locally.

- Many existing and competing businesses would be blighted or undermined by the presence of a regional casino.”

The SSA also adds (14.25), “ Policy CA1 is likely to lead to problem gambling and give rise to health issues and potentially increase health inequalities. The CA1 would be more likely to undermine regeneration objectives than support them.”

We have almost nothing to say in favour of a regional casino. Despite the declaration of the RSS (CA1) that there should be good public transport provision for a casino, it is a leisure facility that most people will choose to drive to, an especially important issue as some may make long journeys. Thus the problems of congestion and carbon emissions will be increased by popularity of such an establishment. While it will bring some income into the area through customers’ use of local shops and food and drink outlets this will be insufficient to offset the many disadvantages listed above by the SSA. The general degradation of a region always created by an influx of visitors through a largely rural area would appear inevitable in the South West if this proposal were allowed to go ahead.

10.2. Conclusions

We agree with the SSA when it states that policy CA1 should be deleted from the Draft RSS and when it states (14.42): “More benign forms of economic development activity should be pursued in order to ensure that the South West’s economy is placed on a more sustainable footing in the long-term.”

Notes

1. The reason behind the first Gulf War in 1991 was to deter Saddam from gaining control of the Saudi oilfields. It was also a major reason for the revolutions in the Ukraine, Georgia and Krygyzstan, as well as the military interventions in Afganistan and Yugoslavia. All of these offer key oil transit routes from the Caspian Sea Basin, which holds the world’s largest untapped fossil fuel resources, worth up to $5 trillion. Similar reasons can be found for Russian intervention in Chechnya, part of the northerly transit route between the Caspian and Black Sea. It is certainly why the US got involved in the war with Iraq, with its huge oil reserves, and why the US is concerned about Iran and the large reserves there. All of this serves to explain US determination to control this fulcrum.

2. An alternative strategy is to take advantage of the rising oil price to develop unconventional oil sources, notably the Athabascan tar sands in Canada and the Venezuelan Orinoco heavy oils. However, the downsides in terms of cost, manpower, water shortages and above all CO2, are prohibitive. Cost-wise, the International Energy Agency considers that investment needed in oil and gas over the next 25 years to meet an expected 50% increase in global demand will be $5 trillion, more than four times the entire GNP of the UK. The biggest constraint, however, is environmental. It takes almost as much energy to mine, process, refine and upgrade the oil which is extracted from tar sand as the energy contained in the light oil produced. Worse still, the processing releases five to 10 times more greenhouse gases than a barrel of conventional oil. This is the exact opposite of the scientists’ requirements for the world to cut greenhouse gas emissions by at least 60% by 2050.

3. Green Party report into the expansion of Bristol Airport :
http://www.glosgreenparty.org.uk/index.php?option=com_content&task=view&id=923&Itemid=72

4. Friends of the Earth report “Why airport expansion is bad for rural economies” (August 2005). http://www.foe.co.uk/resource/briefings/regional_tourism_deficit.pdf

5. A Green Party report by Professor John Whitelegg, Dr. Spencer Fitz-Gibbon with Dr. Seth Crook, “Aviation’s Economic Downside” (December 2003).
http://www.greenparty.org.uk/files/reports/2004/AED3.htm

6. Figures on jet fuel and greenhouse gases based on 80% occupancy on jumbo jet DC-747. All greenhouse gases expressed as warming equivalent in CO2. Source : air travel calculator at www.chooseclimate.org and United Nations Environment Programme.

7. See Green Party housing policy at :
http://policy.greenparty.org.uk/mfss/housing.html

8. Environment Agency, “State of the Environment in the South West 2006”.
http://www.swenvo.org.uk/publications/SOE_2006_FINAL.pdf

9. Kambites et al, “Green Infrastructure Planning in the Swindon Urban-Rural Fringe” (2006), Countryside and Community Research Unit, University of Gloucestershire, available at http://www.glos.ac.uk/shareddata/dms/22B2F402BCD42A03964FAF8895B2E58E.pdf